State Advances NAMI Collection Proposal to CMS

With the support of LeadingAge New York and other groups, the Department of Health (DOH) has just submitted a written proposal to the Centers for Medicare & Medicaid Services (CMS) to assume responsibility for collecting net available monthly income (NAMI) amounts from Medicaid residents in nursing homes. 

Traditionally, nursing homes have been responsible for collecting NAMI amounts from their residents. As the nursing home benefit and population is transitioned to managed care (a proposal which is currently under review by CMS), Medicaid managed care plans will have primary responsibility for NAMI collection for their enrollees. Increasing the number of entities trying to collect these amounts is not likely to improve the overall collection effort. Through the MRT process, LeadingAge NY has consistently advocated for the State or its designee to take over this function. 

LeadingAge NY worked closely with its association colleagues and DOH to survey our respective memberships on their experiences with NAMI collection. Based on responses from about 70 percent of all nursing homes in the state, an estimated $76.3 million of NAMI funds went uncollected during 2012, representing approximately 11.1 percent of the total NAMI liability. DOH’s NAMI workgroup, on which LeadingAge NY was represented, oversaw the survey process.      

DOH is asking CMS to waive federal regulations to allow DOH or a State contractor to take over NAMI collection, something that apparently no other State has done. We will keep our nursing home and managed care plan members posted on further developments in this area.

Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866